ITAT : Interest u/s 201(1A) not compensatory, applicable even when deductee has Nil tax liability

Visakhapatnam ITAT upholds levy of interest u/s 201(1A) for AY 2013-14 and 2014-15 in case of assessee failing to deduct tax at source u/s 194J, rejects assessee’s contention that since the deductee had filed nil return of income and had no tax liability, even after taking into account receipts from assessee, interest u/s 201(1A) was not leviable; Notes that proviso to Sec. 201(1A) inserted w.e.f July 1, 2012 makes it very clear that even though the assessee is not deemed to be 'assessee in default' under the first proviso to Sec. 201(1), the interest u/s 201(1A) shall be payable from the date on which such tax is deductible to the date of furnishing of return of income by such deductee; Holds that the tax liability in the hands of the deductee has no connection with charging of interest u/s 201(1A), distinguishes assessee's reliance on co-ordinate bench rulings as they pertained to AY prior to amendment to Sec. 201(1A); Relies on Calcutta  HC judgment in Kanoi Properties Pvt. Ltd to hold that charging of interest from the date on which the tax was required to be deducted till the date of furnishing of return of income by the deductee is automatic and mandatory; Rejects assessee’s contention that interest u/s 201(1A) was compensatory in nature relying on Madras HC decision in Chennai Properties & Investments Ltd.:ITAT